ML022390105
| ML022390105 | |
| Person / Time | |
|---|---|
| Issue date: | 08/28/2002 |
| From: | Beckner W NRC/NRR/DRIP/RORP |
| To: | |
| Shapaker, J., NRR/RORP, 301-415-1151 | |
| Shared Package | |
| ml022390102 | List: |
| References | |
| OMB 3150-0195, TAC M3216 RIS-02-014 | |
| Download: ML022390105 (8) | |
See also: RIS 2002-14
Text
OMB Clearance No. 3150-0195
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001
August 28, 2002
NRC REGULATORY ISSUE SUMMARY 2002-14
PROPOSED CHANGES TO THE SAFETY SYSTEM UNAVAILABILITY
PERFORMANCE INDICATORS
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to inform addressees that beginning on September 1, 2002, the agency will start a 6-month pilot
program to evaluate changes to the safety system unavailability (SSU) performance indicators
(PIs). The pilot program will be assessed midway through the test period to determine if more
than six months are needed to obtain meaningful results. This RIS and its attachments provide
guidance to participating addressees for submitting PI data to the NRC. Addressee
participation in this pilot program is voluntary. Therefore, this RIS requires no action or written
response on the part of an addressee.
BACKGROUND
The Reactor Oversight Process (ROP) is directly linked to the NRCs mission. That framework
includes cornerstones of safety. Within each cornerstone, a broad sample of information on
which to assess licensee performance in risk-significant areas is gathered from PI data
submitted by the licensees and from the NRCs risk-informed baseline inspections. The PIs are
not intended to provide complete coverage of every aspect of plant design and operation, but
they are intended to be indicative of performance within related cornerstones. The data
submitted by each licensee is used to calculate the PI values, which are then compared to risk-
informed, objective thresholds.
NRC has established a formal process to (1) address questions and feedback from internal and
external stakeholders, (2) make changes to existing PIs and thresholds based on lessons
learned, and (3) develop new PIs and associated thresholds. NRC used this formal process
(documented in NRC Inspection Manual Chapter 0608, Performance Indicator Program) to
evaluate the changes described in this RIS.
Package: ML022390102
Page 2 of 5
SUMMARY OF ISSUE
Results from the ROP Pilot Program (SECY-00-0049, dated February 24, 2000) gave the first
indications that there were problems with the SSU PIs. Other feedback that confirmed this
conclusion were stakeholder feedback from public workshops, NRC/Industry Working Group
meetings, and the ROP feedback process. In response to these problems, NRC formed an ad
hoc committee, the Safety System Unavailability Planning Committee. The Committee has
identified the following major issues: (1) the use of risk-significant system functions versus
design-basis functions, (2) the use of T/2 to estimate fault exposure time in the current SSU PI,
(3) the evaluation of design and performance deficiencies that are not detected through regular
surveillance tests, but rather through the significance determination process (SDP), and (4) the
manner in which support systems (e.g., the component cooling water or service water system)
unavailability should affect the availability of the monitored safety system.
Following the formal PI process, steps have been taken to modify the existing SSU PI.
Numerous public meetings have been held since February 2000 to discuss and develop
alternate SSU PIs and the NRC has agreed to pilot test a set of performance indicators under
the mitigating systems cornerstone. These PIs will be referred to as the mitigating system
performance index (MSPI). The MSPI monitors the performance of the risk-significant functions
of selected systems as described in the guidance documents attached to this RIS. This index
consists of system unavailability and system unreliability elements for the monitored system.
Attachments 1 and 2 provide descriptions of the MSPI.
The following plants have volunteered to participate in the pilot test: Salem 1 and 2,
Hope Creek, Limerick 1 and 2, Millstone 2 and 3, Prairie Island 1 and 2, Braidwood 1 and 2,
Surry 1 and 2, Palo Verde 1, 2, and 3, San Onofre 2 and 3, and South Texas 1 and 2.
The purpose of the pilot program is to collect data to determine whether the MSPI is an
improvement over the existing SSU PIs at indicating performance in the mitigating systems
cornerstone, and does not introduce new unintended consequences.
The NRC will follow its standard practices in conducting the pilot test to determine the efficacy
of the proposed MSPI. This includes considering:
1.
differences between data collected for the current SSU PIs and the MSPI;
2.
the comparability of the data reported for the SSU PI and the MSPI;
3.
the ability of licensees to report the requested data accurately and with minimal need
for clarification;
4.
the ability of the MSPI to reduce the potential for unintended consequences
Page 3 of 5
5.
whether the MSPI will satisfy ROP objectives:
Maintain safety: Can MSPI indicate significant departures from expected
performance that warrant additional attention?
Increase public confidence: Is the MSPI at least as understandable as the current
SSU PI?
Improve the efficiency and effectiveness of NRC processes: Are fewer NRC
resources being spent on single-demand failure SDPs and fault exposure data
issues?
Reduce unnecessary regulatory burden: Does the MSPI reduce licensee reporting
burden and resource expenditure. For example, does the MSPI avoid duplication
of records for the maintenance rule, probabilistic risk assessment, and the ROP
and reduce resources allocated to single demand failure SDP evaluations?
Attachment 3 of this RIS provides additional success criteria which address the technical
adequacy of the MSPI.
NRC will continue to use existing PIs to assess plants participating in the pilot program.
Therefore, no thresholds will be applied to the data reported in the MSPI pilot.
Midway through the 6-month pilot program, the NRC will decide whether to extend the program
to ensure that the test results are meaningful and adequate to gather insights. The reporting
guidance in the attachments to this RIS may be modified during the pilot to reflect insights
gained from table top exercises and the data received.
Based on the results of this pilot program and stakeholder feedback, the NRC will decide
whether to replace current PIs with the MSPI.
VOLUNTARY ACTION
Addressees that choose to participate in the pilot program should conform to the guidance in
this RIS for the voluntary submission of PI data. Send the September 2002 PI data as an
attachment to an e-mail message addressed to pidata@nrc.gov on or before October 21, 2002,
and by the 21st of each month thereafter for the preceding month. Include MSPI Pilot-Test
Data in the subject line of the e-mail. The data reporting phase of the pilot test ends on
March 21, 2003, with the submission of data for the preceding month.
All questions and comments generated by pilot plants and the nuclear industry should be sent
to tch@nei.org. Questions and comments from the NRC and the public should be sent to
reactoroversight@nrc.gov. Questions and comments submitted to this e-mail address will be
discussed and evaluated during the next MSPI Working Group monthly meeting. Responses
will be provided within 2 weeks of the monthly MSPI Working Group meeting.
Page 4 of 5
An external NRC Web site, http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/mspi.html, has
been set up for stakeholders to obtain updated guidance on conducting the pilot program. The
updated guidance will be provided in the form of revisions to the attachments to this RIS,
namely, Attachment 1, Section 2.2, Mitigating Systems Cornerstone, of NEI 99-02,
Regulatory Assessment Performance Indicator Guideline (Draft); and Attachment 2,
NEI 99-02, Appendix F, Methodologies For Computing the Unavailability Index, the
Unreliability Index and Determining Performance Index Validity (Draft).
BACKFIT DISCUSSION
This RIS requires no action or written response. Any action on the part of addressees to collect
and transmit PI data in accordance with the guidance contained in this RIS is strictly voluntary
and, therefore, is not a backfit under 10 CFR 50.109. Therefore, the staff did not perform a
backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal
Register because the NRC has worked closely with NEI, industry representatives, members of
the public, and other stakeholders since early 1998 on the development of NRCs Reactor
Oversight Process, including the collection of PI data. The NRC has solicited public comment
on its intent to collect PI data in five Federal Register notices (dated January 22, April 12,
May 26, July 19, and August 11, 1999), four regulatory issue summaries (RIS 99-06 and
RIS 2000-08, Voluntary Submission of Performance Indicator Data; RIS 2000-21, Changes to
the Unplanned Scram and Unplanned Scram with Loss of Normal Heat Removal Performance
Indicators; and RIS 2001-25, NEI 99-02, Revision 2, Voluntary Submission of Performance
Indicator Data), and at numerous public meetings. The NRC will also issue a Federal Register
notice soliciting public comment on the proposed PIs described in this RIS.
PAPERWORK REDUCTION ACT STATEMENT
This regulatory issue summary contains voluntary information collections that are subject to the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were
approved by the Office of Management and Budget, clearance number 3150-0195, which
expires October 31, 2002.
The burden to the public for this voluntary information collection is estimated to average 240
hours per response for the initial response and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per response thereafter. This effort
includes the time for reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the information collection. Send
comments regarding this burden estimate or any other aspect of this information collection,
including suggestions for reducing the burden, to the Records Management Branch (T-6 E6),
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by Internet electronic
mail to INFOCOLLECTS@nrc.gov; and to the Desk Officer, Office of Information and
Regulatory Affairs, NEOB-10202, (3150-0195), Office of Management and Budget,
Washington, DC 20503.
Page 5 of 5
Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to respond to, an
information collection unless the requesting document displays a currently valid OMB control
number.
If you have any questions about this matter, contact the person listed below.
/RA/
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Technical Contact:
301-415-2956
E-mail: SXS5@nrc.gov
Attachments:
1. Section 2.2, Mitigating Systems Cornerstone, of NEI 99-02,
Regulatory Assessment Performance Indicator Guideline (draft)
2. NEI 99-02, Regulatory Assessment Performance Indicator Guideline,
Appendix F, Methodologies For Computing the Unavailability Index,
the Unreliability Index, and Determining Performance Index Validity (draft)
3. Mitigating System Performance Index Pilot Program Success Criteria (draft)
4. List of Recently Issued NRC Regulatory Issue Summaries
- See previous concurrence
OFFICE OE:RORP:DRIP
Tech Editor
IIPB:DIPM
SC:IIPB:DIPM
NAME
JWShapaker*
PKleene*
SSanders*
MSatorious*
DATE
08/26/2002
08/22/2002
08/19/2002
08/21/2002
OFFICE BC:IIPM:DIPM
SC:RORP:DRIP
PD:RORP:DRIP
NAME
CCarpenter*
HMcGurren*
TReis*
WDBeckner
DATE
08/21/2002
08/21/2002
08/27/2002
08/28/2002
Attachment 3
Page 1 of 1
Mitigating System Performance Index Pilot Program
Success Criteria (Draft)
The Mitigating System Performance Index (MSPI) pilot program objectives and success criteria
listed below will be considered to have been met if there is general agreement among the NRC
staff, industry stakeholders, and public stakeholders that they have been met.
1.
The occurrence of a single failure of an MSPI monitored component by itself,
absent any other failures or unavailabilities, should rarely exceed the green/white
MSPI threshold as measured from the baseline value. The term rare is defined
as minimizing the inconsistencies across plants, within plants, and within systems
such that there is no undue burden on resources, and the objective of having
consistent publicly displayed results can be achieved.
2.
False positive and false negative rates can be established for the chosen statistical
method, and instances where the MSPI cannot meet the criteria are rare.
3.
Instances where the results from the MSPI calculational methodology are not
consistent with the SPAR-3 models are rare, and the differences are explainable.
4.
The MSPI pilot plant participants can identify and compile the risk significant
functions for the monitored systems in a readily inspectable format, and can
compile a set of predetermined success criteria for those risk significant functions.
5.
The active components in the monitored systems are appropriate for inclusion in
the MSPI and are a manageable number of components under the MSPI.
6.
By the end of the pilot program, inspection procedures and MSPI pilot guidelines
are sufficiently detailed to minimize MSPI Questions and NRC feedback forms.
7.
MSPI Questions and NRC feedback do not reveal any unresolvable issues.
8.
Data collection inconsistencies between the maintenance rule and the MSPI can
be reconciled in order to eliminate or significantly reduce separate reporting.
9.
Differences between the linear approximation models generated by licensee
probabilistic risk assessments and those generated by the NRC SPAR-3 models
can be reconciled.
______________________________________________________________________________________
OL = Operating License
CP = Construction Permit
Attachment 4
Page 1 of 1
LIST OF RECENTLY ISSUED
NRC REGULATORY ISSUE SUMMARIES
_____________________________________________________________________________________
Regulatory Issue
Date of
Summary No.
Subject
Issuance
Issued to
_____________________________________________________________________________________
2002-13
Confirmation of Employment
Eligibility
08/27/2002
All holders of operating licenses
for nuclear power reactors.
2002-12
NRC Threat Advisory and
Protective Measures System
Various
Various
2002-11
Requalification Program Test
Results for Okonite Okolon Single-
Conductor Bonded-Jacket Cable
(Followup to Regulatory Issue
Summary 2000-25)
08/09/2002
All holders operating licenses for
nuclear power reactors, except
those who have permanently
ceased operations and have
certified that fuel has been
permanently removed from the
reactor vessel.
2002-10
Revision of the Skin Dose Limit in
07/09/2002
All U.S. Nuclear Regulatory
Commission material licensees.
2002-09
Preparation and Scheduling of
Operator Licensing Examinations
06/06/2002
All holders of operating licenses
for nuclear power reactors, except
those who have permanently
ceased operations and have
certified that fuel has been
permanently removed from the
reactor vessel.
2002-08
Availability of the Topical Report
Program Description and Status of
Staff Reviews on the NRC Web
Site
05/22/2002
All holders of construction permits
or operating licenses for nuclear
power reactors (including those
that have permanently ceased
operations and have certified that
fuel has been permanently
removed from the reactor vessel),
formal nuclear industry groups,
and nuclear steam supply system
vendors.
Note:
NRC generic communications may be received in electronic format shortly after they are
issued by subscribing to the NRC listserver as follows:
To subscribe send an e-mail to <listproc@nrc.gov >, no subject, and the following
command in the message portion:
subscribe gc-nrr firstname lastname